This Privacy Policy is formulated to comply with the requirements of the Personal Data Protection Act 2010 (“Act”). For the purpose of this Privacy Policy, “personal data” shall have the meaning ascribed to it in the Act; the terms “we”, “us”, and “Villamas Group” shall include Villamas Group, its subsidiaries, related companies, and affiliates; and the term “you” refers to yourself, including persons represented by you, customers, visitors, and users of this website.

This Privacy Policy sets out how Villamas Group uses and protects any personal data that you provide to Villamas Group, whether electronically or otherwise via this website or directly to Villamas Group. As a data user, we wish to assure you that we respect your privacy and are committed to maintaining, observing, and safeguarding the confidentiality of your personal data.

This Privacy Policy is not intended to, nor does it, create any contractual rights or any other legal rights, nor does it create any obligations on Villamas Group in respect of, or on behalf of, any other party.

Villamas Group reserves the right to amend this Privacy Policy from time to time without prior notification to reflect changes in the applicable law, our business, or this website. You should, therefore, review this Privacy Policy periodically to ensure you are familiar with its terms. In the event that material changes are made to this Privacy Policy, we will notify you by placing a prominent notice on this website.

1. PERSONAL DATA COLLECTED

1.1 Personal Data which Villamas Group collects includes:

• Any information collected or obtained, such as your name, email address, telephone number, home address, date of birth, national registration identity card number, passport number, occupation, banking details, and such other personal information provided to any member of Villamas Group;
• Any information collected or obtained through any means whatsoever, including when you register online via this Website, which may include personal data such as your name and contact details;
• The content of any forms (electronic or otherwise) that you submit via email or through any other means, requesting us to provide services or information, or to take any actions;
• Information submitted if you participate in surveys or competitions organized by any member of Villamas Group, whether online or otherwise;
• Any messages or comments you submit via this Website, which may include personal data such as your name, email address, and telephone number; and
• Personal information collected when you submit your resume or application to us for employment consideration, or when you submit your company profile or credentials for the purpose of introducing services and/or products to us.

2. CONSENT AND PURPOSE OF COLLECTION

2.1 By providing any of your personal data to Villamas Group, whether online or otherwise, you acknowledge that you have read, understood, and agreed to our Privacy Policy, and you consent to the collection, retention, and use of your personal data by us for any of the following purposes:

• Fulfilling contractual obligations in delivering our products, properties, and/or services, and/or fulfilling your instructions and providing you with services under any of Villamas Group’s businesses;
• Processing your application to purchase our products and/or properties and/or enter into any necessary agreements and/or contracts under Villamas Group’s property development and/or other businesses;
• Marketing products, services, properties, and/or customer loyalty programs, and sending advertising and/or promotional material to you via any communication method—including, without limitation, telephone calls, short message service (SMS), postal service, email, or if you have checked the consent box in the Property Registration & Enquiry Form, Leasing Form, or Corporate Information & Career Form on this Website;
• Carrying out user or customer relationship management procedures, analyses, and/or promotional activities.
• Conducting research on planning, profiling, products, goods, services, properties, and testing for Villamas Group;
• Notifying you of special offers, promotional packages, current and future products, properties, or services that we consider may be of interest to you, as well as sending similar updates and promotions via our newsletter, communication platforms, social media, mobile applications, or email, including products and services offered by appointed third parties;
• Performing statistical analysis, benchmarking, and tracking of your interest in and use of the various sections of this Website and Villamas Group’s businesses;
• Purposes connected with the operation, administration, development, or enhancement of Villamas Group’s business or this Website, including but not limited to credit assessments, background checks, collection of outstanding payments, internal record keeping, and the prevention of crime (such as fraud, money laundering, and bribery);
• Where required by law, where we consider that such use or disclosure is necessary to respond to any claims or legal processes, or where Villamas Group suspects that fraud or unlawful activity has been, is being, or may be engaged in;
• Making such disclosures as may be required for any of the above purposes or as mandated by law;
• Where you have provided your resume, considering you for potential job openings within Villamas Group and, if applicable, reviewing your terms and conditions of employment; and
• Carrying out studies to monitor Villamas Group’s recruitment initiatives.

2.2 Please note that if sufficient personal data is not supplied, or is not satisfactory to Villamas Group, your application or request to Villamas Group for any of the above purposes under clause 2.1 may not be accepted or acted upon.

3. DISCLOSURE

3.1 You further consent that your personal data may be disclosed and transferred within Villamas Group, which may include transfers to other entities of Villamas Group in different jurisdictions. Other than to those individuals and entities listed in clause 3.2, your personal data will not be revealed by Villamas Group to any external party unless we have your permission, or are required to disclose information to governmental or other regulatory authorities for the prevention or detection of crime, for the purpose of investigations, or for compliance with any law or court order. In such events, we may be precluded from seeking your consent or notifying you that disclosure has been made.

3.2 The personal data provided by you may be disclosed by Villamas Group to:

• Any one or more members of Villamas Group;
• Villamas Group’s agents and contractors acting on our behalf;
• Any relevant financial institutions;
• Any referee whose details are provided by you to verify or obtain additional information, including educational institutions and current or previous employers;
• Credit reference agencies;
• Third-party service providers (including those managing this website) for Villamas Group’s operational, administrative, and development requirements;
• Auditors, lawyers, professional advisors, debt collectors, bankers, advertising companies, recruitment agencies, researchers, and utility and security service providers to use, disclose, hold, process, retain, or transfer such personal data for the purposes set out in clause (2.1) above for and on behalf of Villamas Group; and
• Any related, affiliated, holding, subsidiary, or successor entities of Villamas Group, including those established in the future.
• Related business partners and affiliates of Villamas Group.
• Auditors, consultants, accountants, solicitors, professional advisers, contractors, sub-contractors, and appointed third-party service or product providers as determined to be necessary or appropriate.
• Any related third-party property or estate management companies or entities responsible for managing property that customers have purchased, as well as any appointed service providers of Villamas Group in relation to the loyalty program.
• Companies that provide utility services.

3.3 Each of the above parties, other than Regulators and your referees, is similarly bound by a duty of confidentiality to Villamas Group in respect of all information disclosed to them.

3.4 Villamas Group uses and discloses aggregated non-personally identifying information collected through this Website as part of Villamas Group’s process of constantly improving this Website and/or Villamas Group’s business.

4. SECURITY

4.1 We have put in place appropriate physical, electronic, and administrative procedures to safeguard, maintain data integrity, and help prevent unauthorized access, disclosure, loss, or misuse of your personal data.

4.2 While all reasonable precautions are taken to secure your personal data, we cannot guarantee that your information will never be disclosed in a manner inconsistent with this Privacy Policy due to unauthorized or illegal acts of third parties acting in violation of existing laws or the policies of Villamas Group.

5. STORAGE AND RETENTION OF PERSONAL DATA

5.1 Your personal data shall be stored either in hard copy at Villamas Group’s offices or on servers located in Malaysia operated by Villamas Group or its service providers.

5.2 Any personal data supplied by you will be retained by Villamas Group for as long as necessary to fulfill the purposes stated in Clause 2.1 above, or as required to satisfy legal, regulatory, or accounting requirements, or to protect Villamas Group’s interests. As a general rule, the maximum retention period is seven (7) years.

5.3 Villamas Group does not offer online facilities for you to delete your personal data held by Villamas Group.

5.4 Villamas Group will take reasonable steps to protect your personal data from misuse, loss, and unauthorized access, modification, or disclosure.

6. COMMUNICATION OR UTILIZATION DATA

6.1 Through your use of telecommunications services to access this Website, your communications data (e.g., Internet protocol address) or utilization data (e.g., information on the beginning, end, and extent of each access, as well as information on the telecommunications services you accessed) are technically generated and could conceivably relate to personal data.

6.2 To the extent that there is a compelling necessity, the collection, processing, and use of your communications or utilization data will occur and will be performed in accordance with the applicable data privacy protection legal framework.

7. CONFIDENTIALITY

7.1 Personal Data held by Villamas Group will be kept confidential in accordance with this Privacy Policy pursuant to the Act.

7.2 Any questions, comments, suggestions, or information other than personal data sent or posted to this Website, or any part of this Website, by visitors will be deemed voluntarily provided to Villamas Group on a non-confidential and non-proprietary basis.

7.3 Villamas Group reserves the right to use, reproduce, disclose, transmit, publish, broadcast, and/or post elsewhere such information freely, as set out in clause 3.2 above.

8. RIGHT OF ACCESS TO PERSONAL DATA

8.1 Under the Act, you have the right of access to your personal data held by Villamas Group upon payment of a prescribed fee, and the right to request the correction of any personal data that is inaccurate, incomplete, misleading, or not up-to-date.

8.2 If you have any questions regarding this Privacy Policy, wish to request access to or correction of your personal data, or wish to withdraw your consent given to Villamas Group for the processing of your personal data for the purposes set out in clause 2.1 above or for the transfer of your personal data to the parties stated in clause 3.2 above, you may send your request in writing to the following address:

The Personal Data Protection Officer
Villamas Group
B-2-6, Plaza TTDI, Jalan Wan
Kadir 3, Taman Tun Dr Ismail,
60000 Kuala Lumpur, Malaysia.
Email: info@villamas.com
Tel: 03-8957 8883 / Fax: 03-8958 6222

8.3 Villamas Group reserves the right to charge you a reasonable fee for the processing of any data access request.